PRIVACY POLICY

Last Modified: June 20, 2018

72Lux, Inc. DBA Shoppable® (“Shoppable,” “we,” “us,” or “our”) has created this privacy policy (this “Privacy Policy”) because we know that you care about how we use and share the personal information that you provide to us. This Privacy Policy relates to our information collection and use practices in connection with our online services and mobile applications (the “Services”), which are made available to you through a variety of platforms, such as through http://www.Shoppable.com (the “Website”), through Facebook, Twitter, LinkedIn, and other social media (collectively, “Social Media”), and through cell phones, personal digital assistants, and other mobile devices (collectively, the “Mobile Devices”). The Website, our Social Media pages, and the Mobile Devices are collectively referred to as the “Platforms.”

By visiting our Website and/or using our Services on any of the Platforms, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Use.

This Privacy Policy is an important document. We recommend you read it carefully.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Use.

The Information We Collect

1. Personal Information

When you sign up to become a Registered User, shop through our checkout technology, receive our newsletter, or enter any promotion or sweepstakes, you will be required to provide us with personal information about yourself. Such Personal Information includes your name, address, e-mail address, and phone number (collectively, the “Personal Information”). We do not collect any Personal Information from you when you use the Services unless you provide us with the Personal Information voluntarily.

2. Billing Information

When you order products and services from us, you will be required to provide certain information in addition to the Personal Information noted above. Such information may include a debit card number, credit card number, and similar information (collectively, the “Billing Information).

3. Geolocational Information

In order to provide some of the Services including local grocers and retailers, we may, at your consent, collect geolocational information from your Mobile Device, your wireless carrier, your IP address, or certain third-party service providers (“Geolocational Information”). You may decline to allow us to collect such Geolocational Information, in which case Shoppable will not be able to provide certain Services to you. Because your Geolocational Information is subject to abuse by others, please be sure to manage your Mobile Device and privacy preferences on the Services on an ongoing basis.

4. Other Information

In addition to the Personal Information and Geolocational Information that you voluntarily provide to us, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:

a. From Your Activity. Information that we automatically collect when you use the Services, such as the type of Platform you’re using, your IP addresses, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, and similar information concerning your use of the Services.

b. From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use cookies to help us collect Other Information and to enhance your experience using the Services. If you do not want the Platforms to place a cookie on your hard drive, you may be able to turn that feature off on your computer or Mobile Device. Please consult your Internet browser’s documentation for information on how to do this. If you decide not to accept cookies from us, the Services may not function properly. When the Services are made available to you through Facebook, Twitter, LinkedIn, and/or other third-party Social Media sites, please be aware that these other sites maintain their own policies regarding cookies and the collection and use of information. You are responsible for reviewing those policies.

c. From Other Sources. Information that we collect or receive from other sources, such as companies that provide our Services by way of a co-branded or private-labeled website (“Partner Companies”), and platforms like Facebook, Twitter, LinkedIn, and/or other third-party Social Media sites on which you have used the Services in accordance with their terms of use and privacy policies. We may add this information to the information we may have already collected from you via our Platforms in order to improve the products and services we provide.

The Information Collected by or Through Third-Party Advertising Companies

We may share Other Information about your activity on the Platforms with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Platforms and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the site on which the pixel tag is located in order to learn which advertisement brings a user to a given site.

You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Shoppable or partner company marketing email. Registered Users and non-registered users placing and order cannot opt out of receiving transactional e-mails related to their account. We will use commercially reasonable efforts to process such requests in a timely manner. You may manage some of the Personal Information we have about you through your Services account. We may not be able to completely remove your Personal Information from our systems in certain circumstances. For example, we may retain your Personal Information for legitimate business purposes, to establish or defend legal claims, as required by law, or as retained in our data backup systems. Any Personal Information that we retain will continue to be subject to the terms of the Privacy Policy that you last accepted.

How We Use and Share the Information

We use the Personal Information, the Billing Information, the Geolocational Information, and the Other Information to provide you the Services, process your orders, solicit your feedback, inform you about our products and services and those of our third-party marketing partners, to administer our rewards and promotional programs, to provide technical and customer support to you, and to improve our Services to you.

We may share Personal Information, the Billing Information, Geolocational Information, and/or Other Information as described below.

• We share your Personal Information, Billing Information, Geolocational Information, and Other Information with third-party retailers and their agents to provide you with the products and services that you have ordered through our Platforms.

• In order to provide the Services and administer our rewards and promotional programs, we may share your Personal Information and Other Information with our third-party promotional and marketing partners, including, without limitation, business participating in our various programs.

• We may enter into agreements with Partner Companies in which we may provide the Partner Companies with a URL and a customer registration page co-branded with, or private labeled by, the Partner Companies, and the Partner Companies may distribute and promote the URL to their customers. A Partner Company may want access to Personal Information that we collect through this process. As a result, if you register on any of our Platforms through a Partner Company, we may provide your Personal Information to the Partner Company. Because we do not control the privacy practices of our Partner Companies, we encourage you to read and understand their privacy policies.

• We may from time to time share Personal Information and/or Other Information with other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.

• In an ongoing effort to better understand our users and our Services, we may analyze the Other Information and the Geolocational Information in aggregate form in order to operate, maintain, manage, and improve the Services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and Services to current and prospective business partners and to other third parties for other lawful purposes.

• We may employ other companies and individuals to perform functions on our behalf. Examples may include providing marketing assistance, information technology support, and customer service. These other companies will have access to the Personal Information, the Billing Information, the Geolocational Information, and the Other Information only as necessary to perform their functions and to the extent permitted by law.

• We may share some or all of your Personal Information, Billing Information, Geolocational Information, and Other Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

• If we or all or substantially all of our assets are acquired, we expect that the Personal Information, the Billing Information, the Geolocational Information, and the Other Information would be transferred along with the other business assets.

• To the extent permitted by law, we may also disclose Personal Information, the Billing Information, the Geolocational Information, and the Other Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing the such Information is necessary or advisable, for example, to protect the rights, property, or safety of Shoppable or others.

How We Protect Your Information

We take commercially reasonable steps to protect the Personal Information, the Billing Information, the Geolocational Information, and the Other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. We use industry-standard SSL (“Secure Socket Layer”) encryption technology, a secure server, and other physical and procedural safeguards to protect the security of such information. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Platforms may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

Important Notice to Non-U.S. Residents

The Website and the Services are operated in the United States. If you are located outside of the United States, please be aware that any information you provide to us will be transferred to the United States. By using the Services and/or providing us with any information, you consent to this transfer.

European Data Subjects and GDPR

The European Union’s General Data Protection Regulation (Regulation (EU) 2016/679) gives certain rights to European residents in relation to their personal information.

Lawful basis for processing. We will only process your personal information when we have a legal basis to do so. When we do process your personal information, we will do so with your consent or because the processing is necessary: for the performance of a contract with you; to comply with our legal obligations; to pursue our legitimate interests; or to establish or defend a legal claim.

Your rights. Under certain circumstances, you may have the right to: (i) obtain a copy of the personal information we have about you; (ii) update or correct the personal information we have about you; (iii) request that we delete your personal information; (iv) object to how we use your personal information; and (v) withdraw your consent for how we use your personal information.

We may not be able to accommodate your request in every situation, but if that is the case, we will let you know why. Contact us at privacy@Shoppable.com if you wish exercise your rights. We may ask you to verify your identify so that we can comply with your request. All correspondence will be done through email unless you specifically request a different method. We may charge you an administrative fee for subsequent requests.

Complaints. If you are in the European Union and you believe that our processing of your personal information infringes applicable law, you may submit a complaint with a supervisory authority.

Children

We do not knowingly collect Personal Information from children under the age of 13 through the Services. If you are under 13, please do not give us any Personal Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Information through the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us, and we will endeavor to delete that information from our databases.

California Residents

California Shine the Light Law. Under California Civil Code Section 1798.83, California residents who have an established business relationship with Shoppable may choose to opt out of our sharing your Personal Information with third parties for direct marketing purposes. If you are a California resident and (1) you wish to opt out; or (2) you wish to request certain information regarding our disclosure of your Personal Information to third parties for the direct marketing purposes, please send an e-mail to privacy@Shoppable.com or write to us at:

Do Not Track Signals. Some web browsers may transmit “do not track” signals to websites with which the web browser communicates. The Website responds to do not track signals. The website does not currently recognize or respond to do not track signals.

External Websites

The Platforms and the Services may contain links to third-party websites. Shoppable has no control over the privacy practices or the content of any of our Partner Companies, advertisers, sponsors, or other websites to which we provide links. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

Changes to This Privacy Policy

TThis Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Platforms as soon as they go into effect. Changes will be effective immediately but will not apply retroactively. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at privacy@shoppable.com or call 917-265-8470.